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{{#Wiki_filter:,,,OBe-WT"H~ELD  
{{#Wiki_filter:,,,OBe-WT"H~ELD           110lN,5
110lN,5 G:\DRS\Engineering  
                  G:\DRS\Engineering Branch 1\_LicRenewal\Oyster Creek\2008 Outage\lnReport\OC 2008-07
Branch 1\_LicRenewal\Oyster  
                  LRIrev-2A Upfront Guts.doc
Creek\2008  
                  Conte Input for Upfront Guts of Report
Outage\lnReport\OC  
                  Dear Mr. Pardee
2008-07 LRIrev-2A  
                  On December 23, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an
Upfront Guts.doc Conte Input for Upfront Guts of Report Dear Mr. Pardee On December 23, 2008, the U. S. Nuclear Regulatory  
                  inspection at your Oyster Creek Generating Station. The enclosed report documents the
Commission (NRC) completed  
                  inspection results, which were discussed on December 23, 2008, with Mr. T.. Rausch,. Site Vice
an inspection  
                  President, Mr. M. Gallagher, Vice President License Renewal, and other members of your staff
at your Oyster Creek Generating  
                  in a telephone conference observed by representatives from the State of New Jersey.
Station. The enclosed report documents  
                  Part 50 results
the inspection  
                  With respect to activities authorized by 10 CFR 50, the inspectors found no findings of safety
results, which were discussed  
                  significance.
on December 23, 2008, with Mr. T.. Rausch,. Site Vice President, Mr. M. Gallagher, Vice President  
                  With respect to 10 CFR 54 activities, we observed and have come to understand that you are
License Renewal, and other members of your staff in a telephone  
                  implementing regulatory commitments as listed in Appendix A of NUREG 1845 (ml ........ ) and
conference  
                  the proposed license conditions of that document as though you have an approved renewed
observed by representatives  
                  operating license. We also noted that the proposed license conditions of NUREG 1845 for
from the State of New Jersey.Part 50 results With respect to activities  
                  license renewal have evolved to that listed as Attachment 1 of SECY 08-XXX (ml ........... ) As
authorized  
                  an example, the proposed license condition XXX indicated that you will be sending in a
by 10 CFR 50, the inspectors  
                  readiness letter to indicate readiness for inspection, this was not in the proposed license
found no findings of safety significance.
                  condition of NUREG 1845C.                                         (b)(5)
With respect to 10 CFR 54 activities, we observed and have come to understand  
                                                                      (b)(5)                                           Ifi ý"'
that you are implementing  
                                                        (b)(5)
regulatory  
                                                                                              I
commitments  
                  Further, as you well know, an appeal of a licensing board decision regarding the Oyster Creek
as listed in Appendix A of NUREG 1845 (ml ........ ) and the proposed license conditions  
                  application for a renewed license is pending before the Commission related to the adequacy of
of that document as though you have an approved renewed operating  
                  the aging management program for the Oyster Creek drywell.
license. We also noted that the proposed license conditions  
                  The midcycle letter of ................ Indicated that the inspections of
of NUREG 1845 for license renewal have evolved to that listed as Attachment  
                  -                                               (b)(5)
1 of SECY 08-XXX (ml ........... ) As an example, the proposed license condition  
                                                                                                                  7z4 ý
XXX indicated  
                  The NRC is conducting these inspections using the guidance of Inspection Procedure (IP)
that you will be sending in a readiness  
                  71003 "Post-Approval Site Inspection for License Renewal" as a prudent measure in order to
letter to indicate readiness  
                take the opportunity to make observations of Oyster Creek license renewal activities during the
for inspection, this was not in the proposed license condition  
                  last refuel outage prior to entering the period of extended operation. The inspectors reviewed
of NUREG 1845C. (b)(5)(b)(5)Ifi ý"'(b)(5)I Further, as you well know, an appeal of a licensing  
                  selected procedures and records, observed activities, and interviewed personnel.
board decision regarding  
                                                                  (b)(5)
the Oyster Creek application  
                                                                                                            ÷ , /
for a renewed license is pending before the Commission  
kibWrAdw, hithsreconwas delugedm
related to the adequacy of the aging management  
Woedac with the reedom of Informago ftL
program for the Oyster Creek drywell.The midcycle letter of ................  
Exemptions
Indicated  
                                                                                                          &175-  -7
that the inspections  
FOIN"PA       AOC   -j o
of-7z4 ý(b)(5)The NRC is conducting  
 
these inspections  
  A-3
using the guidance of Inspection  
(b)(5)
Procedure (IP)71003 "Post-Approval  
      I ;)I
Site Inspection  
 
for License Renewal" as a prudent measure in order to take the opportunity  
                                                  A-4
to make observations  
The enclosed report records the inspector's observations, absent any determinations on
of Oyster Creek license renewal activities  
adequacy or significance. We are doing this because the proposed regulatory commitments
during the last refuel outage prior to entering the period of extended operation.  
made as a part of the 10 CFR 54 application are not in effect pending the final licensing action
The inspectors  
by the Director of NRR in conjunction with Commissioners' decision on the appeal of the
reviewed selected procedures  
hearing issue. If you have any questions in this regard, please let us know.
and records, observed activities, and interviewed  
Further, the observation of your activities with respect to proposed activities for license renewal
personnel.(b)(5)÷ , /kibWrAdw, hithsreconwas  
indicated that implementation did not go as expected associated with certain proposed
delugedm Woedac with the reedom of Informago  
regulatory commitments. These dealt with the installation of the strippable coating, the
ftL Exemptions
monitoring of the cavity drain trough drain, and the monitoring of the sand bed drains. At the
FOIN"PA AOC -j o&175- -7
exit meeting of December 23, 2008, you indicated that you were conducting a common cause
A-3 (b)(5)I ;)II
analysis in addition to placing this information into your corrective action process, at a minimum,
A-4 The enclosed report records the inspector's  
for future enhancement. With respect to the current situation for your 10 CFR 50 activities, we
observations, absent any determinations  
continue to believe that it is prudent for us to continue conducting observations of your license
on adequacy or significance.  
renewal activities and we plan a team inspection starting March 9, 2009 using the same
We are doing this because the proposed regulatory  
guidance for this inspection     "               (b)(5)       (b)(5)
commitments
                  (b)(5)                   J
made as a part of the 10 CFR 54 application  
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
are not in effect pending the final licensing  
enclosure will be available electronically for public inspection in the NRC Public Document
action by the Director of NRR in conjunction  
Room or from the Publicly Available Records (PARS) component of NRC's document system
with Commissioners'  
(ADAMS). ADAMS is accessible from the NRC Web-site at
decision on the appeal of the hearing issue. If you have any questions  
http://www.nrc.gov/NRC/ADAMS/index.htmi (the Public Electronic Reading Room),
in this regard, please let us know.Further, the observation  
IN LIGHT OF THE REUESTS FOR INFORMATION DD SHOULD SIGN
of your activities  
                                                Sincerely,
with respect to proposed activities  
                                                Darrell Roberts, Director
for license renewal indicated  
                                                Division of Reactor Safety
that implementation  
 
did not go as expected associated  
                                                  A-5
with certain proposed regulatory  
                                        REPORT DETAILS
commitments.  
4.       OTHER ACTIVITIES (OA)
These dealt with the installation  
4OA2 License Renewal Follow-up (IP 71003)
of the strippable  
1.       Background
coating, the monitoring  
Because the application for a renewed license remains under Commission review for final
of the cavity drain trough drain, and the monitoring  
decision, and a renewed license has not been approved for Oyster Creek, the standards used
of the sand bed drains. At the exit meeting of December 23, 2008, you indicated  
to judge the adequacy of selected IP 71003 inspection samples do not apply.
that you were conducting  
This inspection was conducted in order to observe AmerGen's continuing license renewal
a common cause analysis in addition to placing this information  
activities during the last refueling outage prior to Oyster Creek (OC) entering the extended
into your corrective  
period of operation.
action process, at a minimum, for future enhancement.  
Accordingly, the inspectors recorded observations, without any assessment of implementation
With respect to the current situation  
for your 10 CFR 50 activities, we continue to believe that it is prudent for us to continue conducting  
observations  
of your license renewal activities  
and we plan a team inspection  
starting March 9, 2009 using the same guidance for this inspection " (b)(5) (b)(5)(b)(5) J In accordance  
with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure  
will be available  
electronically  
for public inspection  
in the NRC Public Document Room or from the Publicly Available  
Records (PARS) component  
of NRC's document system (ADAMS). ADAMS is accessible  
from the NRC Web-site at http://www.nrc.gov/NRC/ADAMS/index.htmi (the Public Electronic  
Reading Room), IN LIGHT OF THE REUESTS FOR INFORMATION  
DD SHOULD SIGN Sincerely, Darrell Roberts, Director Division of Reactor Safety  
A-5 REPORT DETAILS 4. OTHER ACTIVITIES (OA)4OA2 License Renewal Follow-up (IP 71003)1. Background
Because the application  
for a renewed license remains under Commission  
review for final decision, and a renewed license has not been approved for Oyster Creek, the standards  
used to judge the adequacy of selected IP 71003 inspection  
samples do not apply.This inspection  
was conducted  
in order to observe AmerGen's  
continuing  
license renewal activities  
during the last refueling  
outage prior to Oyster Creek (OC) entering the extended period of operation.
Accordingly, the inspectors  
recorded observations, without any assessment  
of implementation
adequacy or safety significance.
adequacy or safety significance.
IP 71003 verifies license conditions  
IP 71003 verifies license conditions added as part of a renewed license, license renewal
added as part of a renewed license, license renewal commitments, selected aging management  
commitments, selected aging management programs, and license renewal commitments
programs, and license renewal commitments
revised after the renewed license was granted, are implemented in accordance with Title 10 of
revised after the renewed license was granted, are implemented  
the Code of Federal Regulations (CFR) Part 54, "Requirements for the Renewal of Operating
in accordance  
Licenses for Nuclear Power Plants."
with Title 10 of the Code of Federal Regulations (CFR) Part 54, "Requirements  
2.       Inspection Sample Selection Process
for the Renewal of Operating Licenses for Nuclear Power Plants." 2. Inspection  
        The. inspection team selected a number of inspection samples for review, using the NRC
Sample Selection  
        accepted guidance based on their importance in the license renewal application
Process The. inspection  
        process, as an opportunity to make observations on license renewal activities.
team selected a number of inspection  
        Inspection observations were considered, in light of pending 10 CFR 54 license renewal
samples for review, using the NRC accepted guidance based on their importance  
        commitments and license conditions, as documented in NUREG-1875, "Safety
in the license renewal application
        Evaluation Report (SER) Related to the License Renewal of Oyster Creek Generating
process, as an opportunity  
        Station," as well as programmatic performance under on-going implementation of 10
to make observations  
        CFR 50 current licensing basis (CLB) requirements.
on license renewal activities.
        The reviewed SER proposed commitments and license conditions were selected based
Inspection  
        on several attributes including: the risk significance using insights gained from sources
observations  
        such as the NRC's "Significance Determination Process Risk Informed Inspection
were considered, in light of pending 10 CFR 54 license renewal commitments  
        Notebooks," revision 2; the extent and results of previous license renewal audits and
and license conditions, as documented  
        inspections of aging management programs; the extent or complexity of a commitment;
in NUREG-1875, "Safety Evaluation  
        and the extent that baseline inspection programs will inspect a system, structure, or
Report (SER) Related to the License Renewal of Oyster Creek Generating
        component (SSC), or commodity group.
Station," as well as programmatic  
        For each commitment and on a sampling basis, the inspectors reviewed supporting
performance  
 
under on-going implementation  
                                      A-6
of 10 CFR 50 current licensing  
documents including completed surveillances, conducted interviews, performed visual
basis (CLB) requirements.
inspection of structures and components including those not accessible during power
The reviewed SER proposed commitments  
operation, and observed selected activities described below. The inspectors also
and license conditions  
reviewed selected corrective actions taken as a consequence of previous license
were selected based on several attributes  
renewal inspections.
including:  
 
the risk significance  
A-7
using insights gained from sources such as the NRC's "Significance  
I . . I
Determination  
                                                      A-8
Process Risk Informed Inspection
        3.     Review Details
Notebooks," revision 2; the extent and results of previous license renewal audits and inspections  
        3.1     NRC Unresolved Item
of aging management  
        10 CFR 50 existing requirements (e.g., current licensing basis (CLB)
programs;  
        xxx USE words from PN
the extent or complexity  
        * The conclusions of PNO-1-08-012 remain unchanged
of a commitment;
        " An Unresolved Item (URI) will be opened to evaluate whether existing current licensing basis
and the extent that baseline inspection  
        commitments were adequately performed and, if necessary, assess the safety significance for
programs will inspect a system, structure, or component (SSC), or commodity  
        any related performance deficiency.
group.For each commitment  
        * The issues for follow-up include the strippable coating de-lamination, reactor cavity trough
and on a sampling basis, the inspectors  
        drain monitoring, and sand bed drain monitoring.
reviewed supporting  
        e The commitment tracking, implementation, and work control processes will be reviewed,
A-6 documents  
        based on corrective actions resulting from AmerGen's review of deficiencies and operating
including  
        experience, as a Part 50 activity.
completed  
        3.2     Drywell Floor Trench Inspections
surveillances, conducted  
interviews, performed  
visual inspection  
of structures  
and components  
including  
those not accessible  
during power operation, and observed selected activities  
described  
below. The inspectors  
also reviewed selected corrective  
actions taken as a consequence  
of previous license renewal inspections.  
A-7  
I ..I A-8 3. Review Details 3.1 NRC Unresolved  
Item 10 CFR 50 existing requirements (e.g., current licensing  
basis (CLB)xxx USE words from PN* The conclusions  
of PNO-1-08-012  
remain unchanged" An Unresolved  
Item (URI) will be opened to evaluate whether existing current licensing  
basis commitments  
were adequately  
performed  
and, if necessary, assess the safety significance  
for any related performance  
deficiency.
* The issues for follow-up  
include the strippable  
coating de-lamination, reactor cavity trough drain monitoring, and sand bed drain monitoring.
e The commitment  
tracking, implementation, and work control processes  
will be reviewed, based on corrective  
actions resulting  
from AmerGen's  
review of deficiencies  
and operating experience, as a Part 50 activity.3.2 Drywell Floor Trench Inspections
}}
}}

Latest revision as of 05:07, 14 November 2019

Draft Ltr. from D. Roberts of USNRC to C. Pardee of Exelon Generation Company, Regarding Oyster Creek Generating Station - NRC License Renewal Follow-Up IR 05000219-2008-007, Rev 2a
ML091980299
Person / Time
Site: Oyster Creek
Issue date: 06/17/2009
From: Darrell Roberts
Division of Reactor Safety I
To: Pardee C
Exelon Generation Co
References
FOIA/PA-2009-0070 IR-08-007
Download: ML091980299 (7)
v • d • e


See also: IR 05000219/2008007

Text

,,,OBe-WT"H~ELD 110lN,5

G:\DRS\Engineering Branch 1\_LicRenewal\Oyster Creek\2008 Outage\lnReport\OC 2008-07

LRIrev-2A Upfront Guts.doc

Conte Input for Upfront Guts of Report

Dear Mr. Pardee

On December 23, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Oyster Creek Generating Station. The enclosed report documents the

inspection results, which were discussed on December 23, 2008, with Mr. T.. Rausch,. Site Vice

President, Mr. M. Gallagher, Vice President License Renewal, and other members of your staff

in a telephone conference observed by representatives from the State of New Jersey.

Part 50 results

With respect to activities authorized by 10 CFR 50, the inspectors found no findings of safety

significance.

With respect to 10 CFR 54 activities, we observed and have come to understand that you are

implementing regulatory commitments as listed in Appendix A of NUREG 1845 (ml ........ ) and

the proposed license conditions of that document as though you have an approved renewed

operating license. We also noted that the proposed license conditions of NUREG 1845 for

license renewal have evolved to that listed as Attachment 1 of SECY 08-XXX (ml ........... ) As

an example, the proposed license condition XXX indicated that you will be sending in a

readiness letter to indicate readiness for inspection, this was not in the proposed license

condition of NUREG 1845C. (b)(5)

(b)(5) Ifi ý"'

(b)(5)

I

Further, as you well know, an appeal of a licensing board decision regarding the Oyster Creek

application for a renewed license is pending before the Commission related to the adequacy of

the aging management program for the Oyster Creek drywell.

The midcycle letter of ................ Indicated that the inspections of

- (b)(5)

7z4 ý

The NRC is conducting these inspections using the guidance of Inspection Procedure (IP)

71003 "Post-Approval Site Inspection for License Renewal" as a prudent measure in order to

take the opportunity to make observations of Oyster Creek license renewal activities during the

last refuel outage prior to entering the period of extended operation. The inspectors reviewed

selected procedures and records, observed activities, and interviewed personnel.

(b)(5)

÷ , /

kibWrAdw, hithsreconwas delugedm

Woedac with the reedom of Informago ftL

Exemptions

&175- -7

FOIN"PA AOC -j o

A-3

(b)(5)

I ;)I

A-4

The enclosed report records the inspector's observations, absent any determinations on

adequacy or significance. We are doing this because the proposed regulatory commitments

made as a part of the 10 CFR 54 application are not in effect pending the final licensing action

by the Director of NRR in conjunction with Commissioners' decision on the appeal of the

hearing issue. If you have any questions in this regard, please let us know.

Further, the observation of your activities with respect to proposed activities for license renewal

indicated that implementation did not go as expected associated with certain proposed

regulatory commitments. These dealt with the installation of the strippable coating, the

monitoring of the cavity drain trough drain, and the monitoring of the sand bed drains. At the

exit meeting of December 23, 2008, you indicated that you were conducting a common cause

analysis in addition to placing this information into your corrective action process, at a minimum,

for future enhancement. With respect to the current situation for your 10 CFR 50 activities, we

continue to believe that it is prudent for us to continue conducting observations of your license

renewal activities and we plan a team inspection starting March 9, 2009 using the same

guidance for this inspection " (b)(5) (b)(5)

(b)(5) J

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS). ADAMS is accessible from the NRC Web-site at

http://www.nrc.gov/NRC/ADAMS/index.htmi (the Public Electronic Reading Room),

IN LIGHT OF THE REUESTS FOR INFORMATION DD SHOULD SIGN

Sincerely,

Darrell Roberts, Director

Division of Reactor Safety

A-5

REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 License Renewal Follow-up (IP 71003)

1. Background

Because the application for a renewed license remains under Commission review for final

decision, and a renewed license has not been approved for Oyster Creek, the standards used

to judge the adequacy of selected IP 71003 inspection samples do not apply.

This inspection was conducted in order to observe AmerGen's continuing license renewal

activities during the last refueling outage prior to Oyster Creek (OC) entering the extended

period of operation.

Accordingly, the inspectors recorded observations, without any assessment of implementation

adequacy or safety significance.

IP 71003 verifies license conditions added as part of a renewed license, license renewal

commitments, selected aging management programs, and license renewal commitments

revised after the renewed license was granted, are implemented in accordance with Title 10 of

the Code of Federal Regulations (CFR) Part 54, "Requirements for the Renewal of Operating

Licenses for Nuclear Power Plants."

2. Inspection Sample Selection Process

The. inspection team selected a number of inspection samples for review, using the NRC

accepted guidance based on their importance in the license renewal application

process, as an opportunity to make observations on license renewal activities.

Inspection observations were considered, in light of pending 10 CFR 54 license renewal

commitments and license conditions, as documented in NUREG-1875, "Safety

Evaluation Report (SER) Related to the License Renewal of Oyster Creek Generating

Station," as well as programmatic performance under on-going implementation of 10

CFR 50 current licensing basis (CLB) requirements.

The reviewed SER proposed commitments and license conditions were selected based

on several attributes including: the risk significance using insights gained from sources

such as the NRC's "Significance Determination Process Risk Informed Inspection

Notebooks," revision 2; the extent and results of previous license renewal audits and

inspections of aging management programs; the extent or complexity of a commitment;

and the extent that baseline inspection programs will inspect a system, structure, or

component (SSC), or commodity group.

For each commitment and on a sampling basis, the inspectors reviewed supporting

A-6

documents including completed surveillances, conducted interviews, performed visual

inspection of structures and components including those not accessible during power

operation, and observed selected activities described below. The inspectors also

reviewed selected corrective actions taken as a consequence of previous license

renewal inspections.

A-7

I . . I

A-8

3. Review Details

3.1 NRC Unresolved Item

10 CFR 50 existing requirements (e.g., current licensing basis (CLB)

xxx USE words from PN

  • The conclusions of PNO-1-08-012 remain unchanged

" An Unresolved Item (URI) will be opened to evaluate whether existing current licensing basis

commitments were adequately performed and, if necessary, assess the safety significance for

any related performance deficiency.

  • The issues for follow-up include the strippable coating de-lamination, reactor cavity trough

drain monitoring, and sand bed drain monitoring.

e The commitment tracking, implementation, and work control processes will be reviewed,

based on corrective actions resulting from AmerGen's review of deficiencies and operating

experience, as a Part 50 activity.

3.2 Drywell Floor Trench Inspections

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